Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Fall Focus Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

Late on the evening of August 5, 2019, President Trump issued a new Executive order imposing blocking sanctions on the Government of Venezuela (“GoV”).  The order builds on prior limited sanctions imposed on the GoV, as well as blocking sanctions imposed on certain GoV agencies and state-owned companies
Continue Reading Davis Polk Client Memorandum: United States Imposes Blocking Sanctions on the Government of Venezuela

On June 24, 2019, President Trump signed an Executive Order (“EO” or “Order”) imposing new economic sanctions on the Supreme Leader of Iran, Ayatollah Ali Khamenei, and the Iranian Supreme Leader’s Office. The EO blocks all of the Supreme Leader’s property and interests in property in the United States, that
Continue Reading New Economic Sanctions on Iran: More Sound than Fury

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition

On May 8, 2019, the one-year anniversary of his decision to end the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran, President Trump issued a new Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” (the
Continue Reading U.S. Expands Sanctions Targeting Iran’s Metals Sector

On May 3, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Compliance Framework”), a guidance document that sets forth OFAC’s views of the essential elements of an effective economic sanctions compliance program (“SCP”).  OFAC
Continue Reading OFAC Publishes Guidance on Sanctions Compliance Programs

On April 22, 2019, Secretary of State Mike Pompeo announced that the waivers issued to China, Greece, India, Italy, Japan, South Korea, Taiwan and Turkey, which allow them to continue to import Iranian oil after the United States fully reinstated secondary sanctions against Iran last fall, will expire on May
Continue Reading U.S. Department of State to Cancel Iranian Oil Waivers

In separate statements on April 17, 2019 coinciding with the anniversary of the Bay of Pigs invasion, U.S. Secretary of State Mike Pompeo and National Security Adviser John Bolton announced several measures intended to increase pressure on Cuba, Venezuela, and Nicaragua, in response to corruption, human rights abuses, and political
Continue Reading U.S. Government Targets “Three Stooges of Socialism” with New Measures Against Cuba, Venezuela, and Nicaragua

On April 8, 2019, the U.S. State Department announced its intent to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under section 219 of the Immigration and Nationality Act, 8 U.S.C. § 1189.  The designation will take effect upon publication in
Continue Reading U.S. Government Adds to Sanctions Against the IRGC with Unprecedented FTO Designation

On March 4, 2019, the U.S. State Department announced that, for the first time, it would permit actions under Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996, Pub. L. 104-114 (the “Libertad Act”), which authorizes U.S. nationals that own claims to property
Continue Reading In Unprecedented but Mostly Symbolic Move, State Department Allows Some Claims under Title III of the Libertad Act